Finding 1161266 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
$1
Year
2025
Accepted
2025-10-22
Audit: 371188
Organization: Milligan University (TN)

AI Summary

  • Core Issue: A significant deficiency was found in the Return to Title IV calculation, where not all disbursed aid was included, leading to incorrect fund totals.
  • Impacted Requirements: Compliance with the 2024-2025 Federal Student Aid Handbook and 34 CFR 668.22 regarding the calculation of earned Title IV funds.
  • Recommended Follow-Up: The financial aid director should ensure all applicable aid is included in calculations and implement verification measures to prevent future errors.

Finding Text

2025‐001 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education - William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Educational Opportunity Grant, ALN #84.007; Teacher Education Assistance for College and Higher Education Grant, ALN #84.379) Criteria: In accordance with the 2024-2025 Federal Student Aid Handbook and 34 CFR 668.22, a school must calculate the amount of earned Title IV funds by applying a percentage to the total amount of Title IV program assistance that was disbursed and that could have been disbursed. Aid included in this calculation to be prorated includes assistance from the Direct Loan, Federal Pell Grant, Iraq and Afghanistan Service Grant, TEACH Grant, and FSEOG programs. Statement of Condition: During the audit, the Return to Title IV calculation for one student failed to include all aid disbursed or able to be disbursed in step one. Therefore, the calculated percentage of aid earned was applied a limited portion of the student’s federal aid, resulting in incorrect fund totals being returned. Questioned Costs: The known monetary error is $220 excess Federal Pell Grant funds being retained on the student’s behalf. During the audit, all students meeting the criteria to warrant a Return to Title IV calculation were tested, so no extrapolation of the monetary error is necessary beyond the identified error. The monetary impact of this deficiency does not exceed the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 9 files for students who withdrew mid-term during the 2024-2025 award year who had received Title IV awards, requiring the University to complete a Return to Title IV calculation. Of these students, this mistake was identified in one instance. Therefore, we consider the error rate as 1 out of the 9 total applicable students, which is 11.11%. Cause and Effect: This error was caused by an oversight by the personnel completing the Return to Title IV calculation, resulting in miscalculation of total Title IV aid earned. Recommendation: The director of financial aid completing any Return to Title IV calculations should ensure that all applicable aid is included in step one of the worksheet. Proper measures may be put into place to verify information input and review the calculation as a whole. View of Responsible Officials: The University concurs with the finding and has provided education and training for the staff responsible for refund calculations. The University will strengthen review procedures of refund calculations in the next award year to ensure compliance with federal guidelines.

Corrective Action Plan

Finding Reference Number: 2025-001 Return to Title IV Funds Summary of Finding: During the R2T4 calculation, all Title IV funds from the Direct Loan, Federal Pell Grant, Iraq and Afghanistan Service Grant, TEACH Grant, and FSEOG programs that were disbursed or able to be disbursed should have be included in determining the amount of earned Title IV funds. In performing the calculation for one student, the institution failed to include all applicable federal aid resulting in $220 of excess Pell grant funds being retained on the student’s behalf. The excess funds of $220 were returned to the DOE in July 2025. Entity’s Corrective Action Plan: The University recognizes the importance of accuracy when performing R2T4 calculations. In this particular situation, the employee who performed the calculation was new in the role and had not previously had responsibility for R2T4 calculations. The University has reassigned this responsibility and has provided education and training for the staff responsible for R2T4 calculations for 2025-26. In addition, the University is requiring a review of each calculation by another member of the financial aid staff with knowledge and training on how to perform the calculations. Anticipated Completion Date: September 1, 2025 Name and Title of Responsible Person: Gus Morgan, Interim Financial Aid Director and VP for Enrollment Services

Categories

Questioned Costs Student Financial Aid

Other Findings in this Audit

  • 1161262 2025-001
    Material Weakness Repeat
  • 1161263 2025-002
    Material Weakness Repeat
  • 1161264 2025-001
    Material Weakness Repeat
  • 1161265 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $8.99M
84.063 FEDERAL PELL GRANT PROGRAM $1.44M
84.033 FEDERAL WORK-STUDY PROGRAM $143,690
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $93,290
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $36,807